Document vyjv0XLVpjxLygrQ5vGM13oeq

Interoffice Communication TO: Distribution TGG: JCL: ERT: MJH: AJO: RF XF:__________ ___________ FROM: DATE: SUBJ: T. G. Grumbles November 26, 1990 RESPONSIBLE CARE DISTRIBUTION CODE OF MANAGEMENT PRACTICE The Distribution Code was approved on November 4. Attached is a "pre-publication" copy for your review. CMA will distribute the final Code in January and our initial self-assessment will be due in May. It appears the final Code has some changes in the areas that we were concerned about. Specifically, the risk assessment portion in Section 1 has been made more reasonable, and the application of the Code elements to off-site, or ex-plant locations has been modified. Also, attached is information on three code implementation workshops. These are practical workshops that attempt to provide guidance and interpretation on the Code elements. I would encourage attendance by plant representatives and S&T staff if feasible. T. G. Grumbles dlj .215 Attachment Distribution: PLANT MANAGERS R. W. Seymour-Aber, L. R. Bauer-Balt, G. D. Williams-Blane, J. Pavao-Hmd, J. Friend-LCCP, J. W. Ware-LCLAB, R. A. Conrad-LCVCM, H. D. Garrison-Okc, P. L. Foote-Prem, V. W. Weiss-Austin TRANSPORTATION CONTACTS T. S. Randolph-LCCP, D. G. Stephens-LCLAB, K. C. Cash-LCVCM, M. F. Ticar-Balt, F. G. Jeanson-Aber, G. C. Lipps-Prem, H. D. GarrisonOkc, R. G. Witt-Blane, R. T. Jackson-Austin, K. R. Perez-Hmd, J. G. Farrier, J. M. Kerlegon, H. L. Duckworth, M. L. Williams, R. B. Quy T. H. Huffman, J. A. DeBernardi, R. D. Gamblin, G. D. Draper, P. Gowan ooooxv*76 VM X u ID' _'C l-KUi'l ritn. >MU(-H'_ i UHEFb Kr-M. u ":.2S3456 P.02 November 26 f 1990 DISTRIBUTION CODE OF MANAGEMENT PRACTICES PURPOSE AMP SCOPE The purpose of the Distribution Code of Management Practices is to reduce the risk of harm posed by the distribution of chemicals to the general public; to carrier, distributor, contractor and chemical industry employees; and to the environment. Adherence to the code will lead to continually safer chemical distribution and help member companies tot o evaluate the risks associated with chemical distribution and methods to reduce those risks; o meet or exceed all regulations and Industry standards governing chemical distribution; o provide emergency advice and/or assistance to people on the scene in the event of a chemical distribution emergency; o develop new technologies and methods to improve chemical distribution safety. The code will also promote improvements in: o employee preparedness and awareness in preventing distribution emergencies; o the safety performance of carriers and other providers of distribution services; o the public's preparedness in responding to chemical distribution emergencies; o the public's understanding of, and confidence in. industry efforts to improve chemical distribution safety. The Distribution Code of Management Practices applies to all modes of transportation (highway., rail, marine, air and pipeline) and to the shipment of all chemicals, including chemical waste. The code also applies to distribution activities (storage, handling, transfer and repackaging) while chemicals are in transit between member companies and their suppliers and customers. The implementation of a number of practices of the code will vary according to the characteristics of the chemical being distributed, the mode of transportation and the type of distribution activity involved. RELATIONSHIP TO RESPONSIBLE CARE GUIDING PRINCIPLES VVV 0000I1*77 This code helps achieve several Responsible Care Guiding Principles: o to recognize and respond to community concerns about chemicals and our operations; mu' '-^i-irrvj rr'ji'l '.rxi'l. i iwt _rH'_ i urtrr H=.rr i. j 1 ,11 if-gSu-if 6 P. 03 November 26, 1990 Distribution Code Page 2 o to make health, safety and environmental considerations a priority in our planning for all existing and new products and processes; o to counsel customers on the safe use, transportation, and disposal of chemicals; o to operate our plants and facilities in a manner that protects the environment and the health and safety of our employees and the public; o to participate with government and others in creating responsible laws, regulations and standards to safeguard the community, workplace and environment; and o to promote the principles and practices of Responsible Care by sharing experiences and offering assistance to others who produce, handle, use, transport or dispose of chemicals. MANAGEMENT PRACTICES Each member company shall have an ongoing chemical distribution safety program that includes senior management commitment through policy, communications and resources to improvements in chemical distribution safety. The program should include the following elements: 1. Risk Management 1.1 Regular evaluations of chemical distribution risks which consider the hazards of the material, the likelihood of accidents/incidents and the potential for human and environmental exposure from release of the material over the route of transport. 1.2 Implementation of chemical distribution risk reduction measures that are appropriate to the risk level. 1.3 Internal reporting and investigation of chemical distribution accidents/incidents, and implementation of preventive measures. 2. Compliance Review and Training 2.1 A process for monitoring changes and interpreting interpretations of new and existing* regulations and industry standards for their applicability to the company's chemical distribution activities, and for implementing those regulations and standards. *Editorial clarification subject to CMA Board approval January 15, 1990 VVV 000011478 ro.'-li-ipyo FROM CHEM. ; IhNUFhCTUREF'z. H=of j 0 F.04 November 26, 1990 Distribution Code Page 3 2.2 Training for all affected company employees in the proper implementation of applicable regulations and company requirements. 2.3 A program for providing guidance and information to carriers, distributors and contractors who perform distribution activities for the company on the company's training and compliance requirements for the activities. 2.4 Regular reviews of company employee, carrier, distributor and contractor compliance with applicable regulations and company requirements. 3. Carrier Safety 3.1 A process for qualifying carriers of all modes and types (common, contract, private and customer controlled) that transport chemicals to and from company facilities that emphasizes carrier safety fitness and regulatory compliance, and includes regular reviews of their performance and compliance, 3.2 Feedback to carriers on their safety performance and suggestions for Improvement. 4. Handling and Storage 4.1 Documented procedures for the selection and use of containers that are appropriate for the chemical being shipped, in compliance with testing and certification requirements, and free of leaks and visible defects. 4.2 Documented procedures for loading chemicals at company facilities that will reduce emissions to the environment, protect personnel and provide securement of the lading during transit. 4.3 Documented procedures for unloading chemicals at the company's facilities that will reduce emissions to the environment, protect personnel, and provide for safe unloading into proper storage facilities. 4.4 Defined criteria for the cleaning and return of tank cars, tank trucks, marine vessels, and returnable/refillable bulk and semi-bulk containers, and for the proper disposal of cleaning residues, 4.5 A program for providing guidance and information to customers, distributors, and other receivers on proper procedures for unloading and storing the company's chemicals. vvv 000011^9 FROM `'Hflljp-H1. i l.-REFb f'LTiX^bc.TR'-.t F. 0? November 26, 1990 Distribution Code PCkge U 4.6 A process for selecting distributors and other facilities that store or handle the company's chemicals In transit that emphasizes safety fitness and regulatory compliance and includes regular reviews of their performance and compliance. 4.7 feedback to distributors and operators of other facilities that store or handle chemicals in transit on their safety performance and suggestions for improvement. 5. Emergency Preparedness 5*1 A process for responding to chemical distribution accident/incidents involving the company's chemicals. 5.2 Documented procedures for making information about the company's chemicals in distribution available to response agencies. 5.3 A program for making facilities and/or training materials available to emergency response agencies. 5.4 Dialogue with state and local emergency planning organiza tions on the distribution and hazards of the company's chemicals to improve community preparedness to respond to chemical distribution emergencies. 5-5 Dialogue with the public on their concerns about chemical distribution safety, actions taken by the industry and the company to improve the safety of chemical distribution, and the effectiveness of emergency preparedness and emergency response assistance. Member Self Evaluation Member companies shall report annually the stage of implementation of each management practice in this code to an agent designated by the Chemical Manufacturers Association. Relationship to Other Codes of Management Practice This Code complements, and should be implemented in conjunction with, current and future Codes of Management Practices. ooooii^80 VVV be designed to give companies ideas andexamplesonimpiementing the Code. Implementation Workshops are also planned, as detailed else where in this issue. December 4, 1990 Four Seasons Philadelphia One Logan Square Philadelphia, PA 1910 (215) 9631500 Additional information is available by contacting Mike Heimoivitz at (202) 887-1360. Agenda Set for Distribution Code Implementation Workshop Mark your calendar and register today for the Responsible Care Distribution Code Implementation Workshops. Designed to assist members in implementing the Dis tribution Code of Management Practices, the workshops are sched uled for: J January 29, 1991 The Weslin Galleria P.O. Box 4487 Houston, TX 77210 (713) 960-8100 March 12, 1991 Hyatt Regency O'Hare 9300 W. Bryn Mawr Avenue Rosemont, IL 60018 (312) 380-4806 The Workshop fee is $100 per per son. A registration form is included with this issue. The evening prior to each workshop, a registration and reception will beheld from 6:30 p.m. to - 7:30 p.m. AGENDA 7:30-5:30 a.m 8.30-8:4Sa.m Re(HireUon Welcome and Opening Remark! IM T DMribulian Cod* 8:45-9:30 a.m Panel DiKiHiion Organising u> Implement the Code loplavwBilAi th* Distribution Cod* of MtongvoNti Prteilua 9:30.10:15 a.m. Panel Diacuseion Rick Management 10:15-10:30 a.m Break 10:30- 11.ISa.m Panel DiecuMion Compliance Review and Training 11:15-Noon Panel Diccueticr Carrier Safely No<m-l:15 p.m. Lunch Speaker 1:15 2:00 p.m. Pane) Diaeuieion Handling and Storage 2:00-2:45 p.m. Panel Diicuieton Emergency Preperednei* 2:45-3:00 p.m CofToe Break 3:00-3:45 p.m. Panel DiKUMion Self-Evaluation 3:45-4:30 p.m. Wrap-up Renew ofQuertion* 4:30 p.m. Adjournment DISTRIBUTION CODE IMPLEMENTATION WORKSHOP REGISTRATION FORM Please register the following pcrson(s) for the Distribution Code Implementation Workshop- A cheek or money order in the amount of($100/person) is enclosed. Mail this form and check or money order, payable to the Chemical Manufacturers Association to: Lillian Amazccn. CMA. 2501 M Street. N.W., Washington. D.C. 20037. Refunds will be made if can cellations are received by CMA before the close of business on November 26. 1900 (Philadelphia), January 21, 1991 (Houston) and March 4.1991 (Chicago). ITKLEPHONE REGISTRATIONS WILL BE CONSIDERED BINDING) Workshop Ijocalioo 12/4/90 _ 1/29/91 3/1291 Philadelphia Houston Chicago Please register the following person(s) for the Workshop: Name Title_____________________________________________ Company ^ Address ^ Telephone VVV 000011481 7